1. Introduct and/or its affiliates ("we", "our" or "us") would like to inform you (the "Client") that your privacy on the internet is of crucial importance to us. The success of our business depends on our ability to maintain the trust of our Clients. During the course of our business, we gather information about our Clients, and we would like to inform our Clients about the type of information we gather, what we do with it and how our Clients can correct or modify the information our Clients entrust us with.
This Privacy Policy applies to all the services offered by circle-hen and it applies to all information collected via and from the Clients’ use of circle-hen services and websites. Please note that this Privacy Policy does not apply to other organizations or persons to which we refer to on such websites through banners or links.
We may amend this Privacy Policy at any time by posting a revised version at or by otherwise notifying the Client. The revised version will be effective at the time it is posted, or notification is given. Consequently, we strongly advise you to revisit periodically to review this Privacy Policy and the Terms of Use.
This Privacy Policy is governed by our Terms of Use.
The processing of personal data is subject to the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the UK Data Protection Act 2018 and any other legislation that replaces the GDPR in the UK.
2. Contact information
Please do not hesitate to contact us with any questions, comments or concerns relating to this Privacy Policy. You may contact us by e-mail to
Personal data means any information relating to an identified or identifiable natural person ("Personal Data"). An identifiable natural person is a person who can be identified, directly or indirectly, by reference to the Personal Data (the "Data Subject").
is responsible for all Personal Data collected. As the controller of Personal Data, determines the purpose and means for usage of Personal Data.
The purpose(s) of Yprocessing of Personal Data relate(s) to the following:
Client identification, monitoring and reporting in accordance with the UK Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (hereafter the “Anti-money Laundering Regulation”)
Authentification of Clients on the platform
Credit assessment of Clients applying for financing through
Transaction information collected in accordance with applicable law
User experience, website optimisation and communication with Clients
For each application, the Client must provide with information specified in Terms of Use or otherwise agreed on. This information includes information on the amount, the identity of the applicant and relevant officers, directors and beneficial owners, recipient of funds, currency conversion, location of funds etc. The said information will be regarded as Personal Data if the information belongs to an identifiable physical person. Such Personal Data will be processed in connection with facilitating the offering of the services, in
In addition, collects Personal Data during the application process as well as during monitoring of transactions relating to the sender and receiver of a transactions. These undertakings are carried out in accordance with YouLe obligations under the Anti-money Laundering Regulation.
collects Personal Data relating to Clients to ensure that meets its requirements under the Anti-money Laundering Regulation. Such information may include names, dates of birth, social security numbers, tax identification numbers and identification documents on beneficial owners of companies, authorised signatories, officers, directors and other relevant personnel. These pieces of information are mandatory information since they are collected and processed in order to comply with applicable laws and regulations.
may also collect Personal Data from third parties to verify the identity and information received by the Client as well as to deter, detect, and prevent fraud and illegal activities and conduct a credit assessment in connection with a Client’s application for financing through . This collection of Personal Data can include a credit reference agency search on the named Client and applicant, including but not limited to directors, beneficial owners and officers, their financial associates and businesses. For the avoidance of doubt, the authorisation to includes an authorisation to conduct credit reference agency searches on all directors, beneficial owners and officers involved with the named Client as well as any guarantors. A record of these searches will be recorded against all applicants and may be seen by other companies if they carry out a credit enquiry.
Communication with Clients is stored for the purpose of providing and managing the services provided by . Said information is deemed Personal Data if it relates to an identifiable person. This information includes e-mails, Instructions, faxes, or telephone calls directed to
may collect information related to the Client’s use of the services and the use of websites by means of cookies, including IP-address. Please read Cookie Policy which is available online at www.youlend.com.
4. How use, disclose and process Personal Data
As listed above, processes Personal Data regarding the Data Subjects in order to provide and manage the services provided by which includes provisioning of financing and credit assessment, instructions, transactions, client service, website optimisation etc. also processes information with the purpose to detect and prevent fraud and violations of legal agreements and to fulfil technical, financial, tax, compliance, administrative functions.
This Privacy Policy forms part of the contract with the Client. Under the contract, the Client authorises to process Personal Data collected from the Client in line with the purposes mentioned in this Privacy Policy. may disclose Personal Data as required by law, including any applicable tax regulation or market rules, or a legislative or supervisory authority or another person who is entitled by law to demand such disclosure, without prior notice to the Client.
Further, may disclose Personal Data to third parties in and outside United Kingdom where such disclosure/processing is for hosting and storing, compliance purposes, fraud prevention, credit assessment or made to enabling the transfer of funds on behalf of or initiated by the Data Subject or the Client. Disclosure of Personal Data may also be made to perform other parts of its services and managing the client relationship, including, but not limited to public authorities and/or cooperation partners such as correspondent banks and service providers. Third parties include but are not limited to third party capital providers.
The Client authorises YouLend to transfer information to any legal entity within the group as well as to any reputable third party in connection with the performance of a credit assessment of the Client and any officers, directors and beneficial owners related to the said Client as well as any guarantors.
has engaged third party data processors for the purpose of hosting and storing information, including Personal Data, for which is responsible. ensures that all processing of Personal Data performed by data processors are performed under the instructions of and in full compliance with the Privacy Policy and applicable law.
When is required or permitted to disclose information, will only disclose Personal Data which is necessary to fulfil the purpose.
In order to process your application, we will supply your business information (which may include personal data) to third party partners, including to Experian and CIFAS and they will give us information about your business and information about people connected to the business, such as a company proprietor or directors. We carry out these checks for the purposes of detecting and preventing fraud and money laundering.
During the time that you have an active account with us, these partners, e.g., Experian may make periodic searches and alert us to any changes about your business, or the people connected to your business, that we may need to investigate as part of our ongoing management of your account.
The ways in which Experian use and share personal information, are explained in more detail at https://www.experian.co.uk/legal/privacy-statement.html.
The ways in which CIFAS use and share personal information as well as potential consequences if fraud is confirmed are explained in more detail at https://www.cifas.org.uk/fpn.
5. Storing and the right to access Personal Data
The Personal Data will be stored no longer than necessary to carry out the specific purpose for which the Personal Data was collected. Under theAnti-money Laundering Regulation, is required to store transaction data and data on the Client for at least five (5) years from the time of termination of the relationship with the Client.
Any Data Subject has the right to request correction, supplementation, deletion, or blocking of such personal information if inaccurate, incomplete, or irrelevant for the purposes of the processing or if processed in any other way that is unlawful by contacting by e-mail to complaints@youlend.com.
is restricted from disclosing Personal Data to the Data Subject which is required to be kept confidential under applicable law, including the Anti-money Laundering Regulation.
6. Security
is committed to handling Personal Data with high standards of information security.
uses computer safeguards such as firewalls and SSL software encryption for many of the services to protect personal information provided to Y enforces physical access controls to their buildings and files, and authorises access to personal information only for those employees who require it to fulfil their job responsibilities.
7. Non-personal information collected by
collects non-personal information, which is not related to an identifiable person, in order to provide and manage its services.
Authentication:
In connection with usage of platform, information is collected to verify the identity of the Client to allow for the use of services, including certification and passwords. also collects the IP address and other identifying information about the computer or device the Client uses to access the accounts, in order to help detect possible instances of unauthorised transactions.
Transaction information:
In connection with each transaction and application, the Client must provide with the information specified in Terms of Use or otherwise agreed on. YouLend retains such information for each transaction and Youlend Advance application. This information includes information on the amount, the identity of the recipient of funds, currency conversion, location of funds, financial information on the Client, ownership, management, website statistics etc. If the information does not relate to an identifiable person, it is deemed non-personal information.
Client identification:
collects information on the Clients for the purpose of facilitating services, identifying the client and to understand the industries of clients which relate to requirements under the Anti-money Laundering Regulation.
Client correspondence information:
Information regarding the Client’s correspondence with will be collected. This information includes emails, instructions, faxes, or telephone calls directed to
8. How use, disclose and process non-personal information collected by
processes non-personal information regarding the Client in order to provide and manage the services, which includes credit assessment, instructions, transactions, client service, website optimisation etc. also processes information with the purpose to detect and prevent fraud and violations of legal agreements and to fulfil technical, financial, tax, compliance, administrative functions.
will not sell, transfer, lease or lend any non-personal information regarding the Client to third parties for their marketing purposes without the Client’s consent. However, in order for to offer its services; enhance the quality of its services from time to time; and protect the interests of the Clients, will in limited circumstances share some of the Client’s information with third parties.
will from time to time disclose and process any non-personal information about the Client as may be required by law, regulation, including any applicable tax regulation or market rules, or a legislative or supervisory authority or another person who is entitled by law to demand such disclosure, without prior notice to the Client.
may also disclose and have processed any non-personal information about the Client to third parties in and outside United Kingdom where such disclosure/processing is for administrative or compliance purposes or fraud prevention or made with a view to enabling the transfer of funds initiated by the Client or performing other parts of its services and managing the client relationship, including, but not limited to public authorities and/or cooperation partners such as credit rating agencies, banks and service providers.
The Client authorises to transfer any non-personal information to any legal entity within the group or companies performing services for group companies in and outside United Kingdom in relation to business, development, compliance, general advisory and statistical purposes. Disclosure of non-personal information will be made in full compliance with any applicable disclosure restrictions.
9. Storing of non-personal information
The collected non-personal information will be stored no longer than necessary to carry out the identified purposes and as reasonably required for business purposes or as reasonably required to comply with any legal obligations, including storage for at least five (5) years from the time of termination of the client relationship.
10. Securing non-personal information
The collected non-personal information will be stored no longer than necessary to carry out the identified purposes and as reasonably required for business purposes or as reasonably required to comply with any legal obligations, including storage for at least five (5) years from the time of termination of the client relationship.
uses computer safeguards such as firewalls and data encryption for many of the services. enforces physical access controls to buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their employment responsibilities.
The security of the Client’s accounts relies on the Client’s protection of the Client’s password, etc. The Client may not share the password with anyone. representatives will never ask for a Client’s password, so any e-mail or other communication requesting the Client’s password should be treated as unauthorised and suspicious and forwarded to complaints info@circle-henpubs.com